Change Consultations

A number of opportunities to simplify and align the P344 ‘Project TERRE’ and P354 ‘Use of ABSVD for non-BM Balancing Services at the metered (MPAN) level’ legal text have been identified. The process for allocating MSID Pair Delivered Volumes to composite MSIDs will be updated to account for both Virtual Lead Party and NETSO inputs. The P344 and P354 processes surrounding the Supplier Volume Allocation Metering System Balancing Services Register will be aligned and simplified.

The Report Phase Consultation closed on 30 July 2019. Two respondents raised concerns that P388 does not take into account balancing actions being provided for regional DNO services, such as voltage support.

This Modification is intended to enable the aggregation of specific Metering Systems’ metered data for network charging purposes, i.e. to support the operation of CUSC Modification Proposals CMP280 and CMP281. This Modification will introduce processes explaining how Suppliers, Half Hourly Data Aggregators (HHDAs) and the Supplier Volume Allocation Agent (SVAA) participate in the aggregation and reporting of storage facilities’ Metering Systems’ metered data and enable the BSC Panel and BSCCo to perform assurance activities in relation to the aggregation of this data.

The Workgroup will review the responses and provide their final views, before submitting the Assessment Report to the Panel on 8 August 2019.

This Modification is concerned with providing clarity in regards to BSC compliance with European Balancing Guideline (EBGL) Article 18 terms and conditions related to balancing, with a specific view of the EBGL Amendment process and Article 62 (Derogations).

The Proposed Modification would make clear that any BSC Modification seeking to amend any BSC provisions that constitute the Article 18 terms and conditions related to balancing, once approved by the Authority (i.e. Ofgem) cannot be progressed as Self-Governance. This is due to the EBGL requirement that any amendment to the Article 18 terms and conditions related to balancing must undergo a separate EBGL Amendment process (detailed in Articles 4, 5, 6 and 10) and be given approval by the Authority.

The Proposed Modification would also specifically preclude any BSC provisions constituting EBGL Article 18 terms and conditions related to balancing from being granted a BSC derogation via the BSC Sandbox process. 

The P374 Workgroup agreed to raise an Alternative Modification that is identical to the Proposed, except in that it will not specifically preclude BSC provisions that constitute Article 18 terms and conditions related to balancing from a BSC derogation. Instead the current process would remain, allowing each application to be assessed on a case-by-case basis.

The Proposer contends that there is no reason for a different treatment of Reserve products and Non BM Fast Reserve should have been captured already in the calculation of the Imbalance Price via the BSAD and via the Reserve Scarcity Price (RSP) methodology.  This Modification is about Non BM Fast Reserve, however, the implementation of this Modification will remove any potential ambiguity and make it clear to the Electricity System Operator, when developing future Balancing Services and associated systems that all Actions should flow through into the Imbalance Price calculation.

P371 seeks to include the price of Non-Balancing Mechanism (BM) Fast Reserve actions into the calculation of the Imbalance Price. The aim is to correct the calculation of the Imbalance Price; guarantee fair and harmonised treatment of all services which cost should be included; provide greater transparency and, ultimately, ensure National Grid’s compliance with the Balancing Services Adjustment Data Methodology Statement (BSAD).

The Balancing Mechanism Reporting Service (BMRS) is the primary channel for providing operational data relating to Great Britain’s (GB) Electricity Balancing and Settlement arrangements, as well as REMIT and European Transparency Regulation data. 

This Modification proposes to move a selection of Balancing Mechanism Reporting Service (BMRS) reporting items, currently set out in BSC Section V ‘Reporting’, to a new Code Subsidiary Document (CSD). This will remove the need to progress a Modification for future amendments while retaining obligations to provide or report required data remain within the BSC.

BMRS changes, which meet newly established criteria designed to speed up the progression of ‘De-Minimis BMRS Changes’ will not be subject to the normal Change Proposal (CP) consultation and will instead be progressed straight for decision. A 15 Working Day objection window will allow market participants to challenge the application of the criteria.

P384 will ensure balancing information required by the European Electricity Balancing Guideline (EB GL) and the European Transparency Regulation (ETR) is available to Market Participants. It will also ensure the Balancing and Settlement Code Company (BSCCo) and National Electricity Transmission System Operator (NETSO) remains compliant with this European legislation.

P366 will amend how Supplier Charge SP08a is applied to Non Half Hourly non-domestic Meters that are hard-to-read (HTR). It is believed that applying Supplier Charge SP08a to HTR Metering Systems is anti-competitive and limits consumer choice. 

P364 will clarify the requirements for configuring and registering Plant and Apparatus in Balancing Mechanism (BM) Units. Specifically where Parties seek to share responsibility for Imports and Export from the same Plant and Apparatus or via the same Boundary Point.

It will also clarify the circumstances and requirements for maintaining BM Unit registration details and seeking to re-register BM Units when the configuration of Plant and Apparatus change

The P363+4 combined Assessment Report was presented to the Panel on 14 MArch 2019. the Panel agreed to amalgamate P363 into P364 and allow P364 to move into the Report Phase. Following amalgamation of P363 and P364, only the P364 page will be updated. The P363 page will not be updated.

The Balancing and Settlement Code (BSC) contains multiple references to European Union (EU) legislation and bodies. Additionally, it also contains text introduced as a result of implementing various EU legislation. Retaining these references and text following the United Kingdom’s (UK’s) withdrawal from the EU without a deal (‘no-deal Brexit’) will mean that the BSC is no longer technically accurate but will remain operable because of the European Union Withdrawal Act 2018.

The requirement to raise a Modification to make additions or changes to the data reported via the Balancing Mechanism Reporting Service (BMRS), is contributing to extended timescales for implementing these updates.

P372 aims to simplify the governance arrangements and reduce the timescales for the publication of data on the Balancing Mechanism Reporting Service (BMRS). 

The BSC is constructed in a way that means the burden of governance can be reduced while maintaining appropriate oversight, by taking BMRS changes out of the Modification process and putting them under formal control of the Change Proposal (CP) process.

P381 proposes to remove Section C3.9.1 of the BSC in respect of ‘quarterly reports’. Currently, the quarterly reports are not viewed by market participants, as the information is made readily available in a more timely and accessible manner elsewhere on the BSC Website. Therefore, the current quarterly reports process utilises Elexon resource that could be better used adding greater value for our customers.

We have issued Urgent Modification Proposal P378 ‘ Introduction of a CM Supplier Interim Charge’ for industry consultation, with responses invited by 5pm on Tuersday 29 January 2019.

P378 seeks to use the BSC to introduce a CM Supplier Interim Charge for Suppliers. This will act as a contingency fund to protect the industry, and customers, from a price shock in the event that the CM standstill is lifted and back payments are required to be made. The Modification solution is based on the recommendations of Issue 76.

We have issued P370 ‘Allow the Panel to designate non-BSC Parties to raise Modifications’ for Report Phase Consultation,  interested parties were invited to respond by Friday 25 January 2019. P370 seeks to allow the BSC Panel, instead of Ofgem, to designate interested third parties to raise Modification Proposals and for Ofgem to become the appeals body. P370 also opens up the Issues process to non-BSC Parties. 

BSC Section T 1.5.3(b)(iii) defines ‘short term’ in relation to Market Index Data as a time period in reference to Gate Closure. Following BSC Modification P342 implemented in November 2017, the deadline for contracts for delivery in a Settlement Period has moved from Gate Closure to the Submission Deadline. P342 did not change the Market Index Definition Statement (MIDS) to reflect this. The 2018 MIDS Review is proposing to amend references of Gate Closure to the Submission Deadline to include trades taken in the hour prior to a Settlement Period in Market Index Data which will impact Market Index Data Providers. This change to the MIDS will need BSC Panel approval in November and approval from the Authority.

We have issued P370 ‘Allow the Panel to designate non-BSC Parties to raise Modifications’ for Assessment Procedure Consultation, which you are invited to respond to by Monday, 12 November 2018. P370 seeks to allow the BSC Panel, instead of Ofgem, to designate interested third parties to raise Modification Proposals and for Ofgem to become the appeals body. P370 also opens up the Issues process to non-BSC Parties.